1. INTRODUCTION
Wagawin Europe GmbH (“Wagawin Europe”, “we”, “us”) respects your privacy and we are responsible for taking care of it. This privacy policy will tell you about your relationship with us. We therefore ask you to read them carefully. This privacy statement is intended for end users of Wagawin Europe’s advertising services, called “Conversational Ads”.
Why you should read this privacy statement:
Many website operators and app developers make their content available free of charge. But of course, they also have to pay their bills. That’s why they broadcast advertisements to you. We help to place advertisements on websites and in apps. As you know, advertising is often annoying and boring. That’s why we create engaging ads and try to show you the advertising that is interesting for you.
To accomplish this, however, we need some information about you that the Data Protection Act (DS-GVO) classifies as personal data. If we store personal data about you, this is only an IP address. We will never be able to find out your name, birthday or address and therefore will not store it. Your personal data will only be processed by us if this is necessary to fulfil the contract if we or the third party have a legitimate interest in the processing or if you have given your consent.
To ensure that you are well informed about your privacy rights we want
- To inform you about the way in which we use your personal data
- To ensure that you understand what information we collect, what we do with it, and most importantly, do not do with it
- To show us responsible for the protection of your data and rights within the framework of this privacy statement
2.OUR SERVICE CALLED “CONVERSATIONAL ADS“
Wagawin Europe provides advertising & marketing services for our Advertiser clients (“Advertisers”). When it comes to advertising, we think engagement matters. Therefore, we provide ad formats, called Conversational Ads, that allow users to engage with advertising content. Our service helps our advertisers’ ads to generate higher awareness and higher performance as we show ads to users that are engaging with advertising content. Furthermore, we aim to make advertising more useful and relevant to users by showing ads that are best tied to their specific interests. Our platform uses interaction data, as well as other data described below, to help Advertisers provide ads to you that are more relevant to you.
3. WHAT PERSONAL DATA WE COLLECT
Our Conversational Ads will be delivered to the Publisher’s Website or App through the Open RTB protocol. To be able to serve a Conversational Ad to a device, it is technically necessary to process the IP address of this device. Beside this, we collect certain data about the ads we served (or attempted to serve) to you. It includes data like what page the ad appeared on, and whether you clicked on or engaged with the ad.
4. HOW WE PROCESS THE PERSONAL DATA WE COLLECT
We use this data to help our Advertisers identify and serve ads to you that are more relevant to you. We also use this data to operate, improve and enhance our services and improve performance of an Advertiser’s ad campaign. Specifically, we use this data for:
- Reporting: Providing Advertisers insights into how their ads are performing and gain insights into their customers. Reporting may include ad metrics such as impressions, engagements and clicks split by dimensions such as website categories, countries or placement types.
- Fraud Detection: By using the ad metrics mentioned above, we focus on real users and dismiss fraudulent traffic.
- Maintenance: The maintenance of the system and the ongoing operations.
5. SHARING OF PERSONAL DATA
Information on how you have engaged with a particular ad is only given to third parties by us if we or the third party have a legitimate interest in passing it on or if you have given your consent.
When we are under a legal obligation to do so, for example to comply with a binding order of a court, or where disclosure is necessary to exercise, establish or defend the legal rights of Wagawin Europe, we share your data with the responsible authority.
We store all personal data of EU citizens on servers within the European Union. In the selection of data centers, we ensure that country-specific data protection laws are fulfilled.
6. RETENTION OF PERSONAL DATA
We store user data for the purpose of the bullets stated in section 4 and may save such data for longer period for invoicing, reporting, discrepancy reasons and to prevent fraud, but in any case, for no longer than 12 months.
After this time or at the time you wish your data to be removed (see section 8) we employ measures to delete it. Personal data collected for other purposes is held no longer than necessary for our business purposes but is anonymized. For example, we retain anonymized impression and click data to ensure we can meet auditing requirements related to services provided or to meet legal requirements.
7. SECURITY
We apply technical, administrative and organizational security measures to protect the data we collect against accidental or unlawful destruction and loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of data over a network, and against other unlawful forms of processing.
8. DATA SUBJECT REQUESTS FOR DATA ACCESS OR DELETION
Article 15 and 17 of the GDPR provides data subjects with the right to access and/or delete personal data that is related to him/her or is about him/her. Wagawin Europe will cooperate with its partners (i.e. Publishers) to help them to fully comply with any access and/or deletion request of a data subject and shall provide its partners with the requested information or confirmation of deletion of such information, as soon as possible.
The GDPR gives you specific rights to your personal data we process; these rights include obtaining copies of it, requesting changes to it, restricting the processing of it, deleting it, or receiving it in a common electronic format so it can be moved to another controller. To exercise your rights, just contact us on the address stated in section 11.
In case that we process your data based on our legitimate interests pursuant to art. 6 para. 1 letter f GDPR, you can contradict the future processing of your data for other purposes not being based on legitimate interest. You also have the right to desire only a limitation of the processing based on certain purposes (art. 18 GDPR).
9. STATEMENT ON LEGITIMATE INTERESTS
Reporting on engagement data may be necessary to help us understand how you engaged with our Engagement Ads, to improve their performance, prevent fraud, illegal activity or security risks, improve our services and ensure we are able to effectively monitor activity on our servers. Engagement data may also be used to improve our solutions. Our lawful basis for this type of processing of Engagement Ad related information is based on our legitimate interest to pursue these goals. It’s important to note that while this information is associated with the individual user, Wagawin Europe’s use of reporting on engagement data is generally limited to aggregated and anonymous inferences drawn from the data collected.